When must related parties prepare transfer pricing documentation?

Related parties are required to apply arm’s length pricing, i.e. transfer pricing, in transactions between them, and depending on the value, they must also prepare documentation.

Segmentation – the greatest challenge of the new transfer pricing rules

One of the key challenges arising from the new transfer pricing regulation is the tightening of segmentation requirements. This is especially relevant for meeting transfer pricing obligations for the 2025 tax year, as this is a transitional year during which certain areas may already be subject to the new rules, while others must continue to be handled under the previous requirements.

 

Is it worth applying the new transfer pricing rules already for 2025?

The transfer pricing regulation that entered into force this year will become mandatory as of 2026; however, for the 2025 tax year it is already optional to apply the rule that no local documentation is required for transactions below HUF 150 million.

Which asset management structure is better suited to preserving the unity of the assets?

 The table below outlines the differences between an asset management foundation and fiduciary asset management.

For the management of very substantial assets, an asset management foundation is the solution.

If we are looking for a solution for the long-term preservation, efficient management, and tax-efficient generational transfer of significant wealth, an asset management foundation may be an appropriate instrument.

What does the principle of “equal pay for equal work” mean?

Since the 1970s, human rights movements and organisations have taken a clear stance and implemented measures to combat wage discrimination. As a result, improvements were noticeable for a long time; however, this process has slowed over the past decade, and since then the average gender pay gap within the European Union has no longer decreased significantly. For this reason, the European Parliament and the Council have set out concrete measures. One of the key instruments is pay transparency, as well as the practical implementation of the principle of “equal pay for equal work.

Don’t leave your GloBE filing and reporting obligations due on June 30 until the last minute

The legal framework for implementing tasks related to the global minimum tax (GloBE) is continuously evolving. In recent months, several implementing regulations have been published. The autumn tax package refined the conceptual framework of the global minimum tax and the rules on information exchange. These provisions must be applied when fulfilling the obligations due on 30 June 2026, and since the rules are quite complex, preparation should not be postponed.

Reform of the EU Social Security Regulation Expected Soon

According to current plans, the proposed reform of the EU social security framework may take place in the first half of 2026, creating new challenges and opportunities in the field of cross-border employment. Changing forms of work, a mobile workforce, and digitalisation are giving rise to increasingly complex legal and administrative issues.